You’re building on-chain in the Cayman Islands. Whether what you issue counts as a financial product decides most of what follows.
Information, not advice
This page is information, not legal advice about your matter. A retainer begins only when a lawyer confirms it.
Start here
Work out what your asset legally is, first
Licensing, marketing and custody all follow from that answer, and the VASP Act decides whether CIMA registration applies.
What to work through, in order
Characterising the asset
Whether the activity is a virtual asset service registrable with CIMA, and whether the asset is also a security. The two questions are assessed separately and both can bite.
Custody and who holds the keys
Providing custody is a distinct registrable virtual asset service, and CIMA expects segregation, key management controls and independent assurance.
Tax treatment
There is no direct taxation locally, and a tax undertaking certificate is commonly obtained. Substance requirements and investor-level taxation elsewhere still apply.
Next steps
What happens if you go ahead
Scoping call
Written scope and fixed-fee quote
Engagement, once a lawyer confirms
Who would handle it
Offices
New York
450 Park Avenue, 3rd Floor, New York NY 10022
San Francisco
28 Geary Street, Suite 625 #133, San Francisco CA 94108